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Chennai South · Velachery Division · Tharamani GST Notice Reply

GST Notice Reply in Tharamani, Chennai

GST Notice Reply cadence for Tharamani firms near Tharamani Bus Stop — handled by a qualified, in-house team

GST Notice Reply for it services businesses in Tharamani near IIT Madras Research Park with WhatsApp document intake and same-day filed-acknowledgement delivery. Call 9566-068-468.

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Quick Answer

What is an ASMT-10 scrutiny notice and how is it issued in Tharamani, Chennai?

ASMT-10 is a notice issued under Section 61 of the CGST Act read with Rule 99 when the proper officer scrutinises a return and identifies discrepancies — typically GSTR-1 vs GSTR-3B mismatch, GSTR-3B vs GSTR-2A/2B ITC variance or turnover differences. The notice specifies the discrepancy and seeks an explanation within 30 days.

Transparent Pricing

GST Notice Reply in Tharamani — Plans & Pricing

Fixed fees · Zero hidden charges · Call 9566-068-468 for a custom quote.

MonthlyAnnualSave 2 Months
Single notice
Standard
Written reply + reconciliation
₹5,000/per notice

  • Notice Review ASMT-10 DRC-01 SCN etc.
  • GSTR-2B vs GSTR-3B Reconciliation
  • Written Reply with Legal Sections
  • Portal Submission of Reply
  • DRC-01A Pre-SCN Voluntary Payment
  • Personal Hearing Attendance
  • Demand Order Analysis Sec 73 / 74
  • Appeal to Appellate Authority APL-01
  • Bank Attachment Recovery Stay
  • Provisional Attachment Sec 83 Response
Most Popular ⭐
Professional
Reply + hearing + demand review
₹15,000/per notice

  • Notice Review ASMT-10 DRC-01 SCN etc.
  • GSTR-2B vs GSTR-3B Reconciliation
  • Written Reply with Legal Sections
  • Portal Submission of Reply
  • DRC-01A Pre-SCN Voluntary Payment
  • Personal Hearing Attendance
  • Demand Order Analysis Sec 73 / 74
  • Appeal to Appellate Authority APL-01
  • Bank Attachment Recovery Stay
  • Provisional Attachment Sec 83 Response
Demand / appeals
Litigation
Full litigation support
₹30,000/per notice

  • Notice Review ASMT-10 DRC-01 SCN etc.
  • GSTR-2B vs GSTR-3B Reconciliation
  • Written Reply with Legal Sections
  • Portal Submission of Reply
  • DRC-01A Pre-SCN Voluntary Payment
  • Personal Hearing Attendance
  • Demand Order Analysis Sec 73 / 74
  • Appeal to Appellate Authority APL-01
  • Bank Attachment Recovery Stay
  • Provisional Attachment Sec 83 Response

Swipe to see all plans

Prices exclude GST. For enterprise pricing, call 9566-068-468.

Why FilingPro?

Why Tharamani Clients Choose FilingPro

Expert GST Notice Reply in Tharamani — qualified professionals, 15+ years experience, zero-penalty track record.

Burden of Proof Allocated Correctly

Under Section 74, the onus of establishing fraud, wilful misstatement or suppression rests on the revenue. Where the SCN merely asserts these elements, the reply demands particulars and evidence — not a rebuttal of bare allegations. Several High Courts have quashed Section 74 orders on this footing alone.

Cross-Examination Insisted Where Statements Are Used

Where the SCN relies on a third-party statement under Section 70, the right to cross-examine is asserted in the reply. Without that opportunity, the statement cannot be used adversely — a principle the Supreme Court has affirmed across the indirect-tax statutes.

Recovery Stay Engineered at Pre-Deposit Stage

Section 107(7) stays Section 79 recovery once the appeal is admitted on pre-deposit. The pre-deposit is structured to admit the appeal at the earliest date so that bank attachment, debtor recovery and provisional attachment under Section 83 are all foreclosed.

Madras High Court Practice Available When Needed

Where the order is jurisdictionally infirm or violates natural justice, a writ before the Madras High Court is available without first exhausting Section 107. The decision between appeal and writ is taken on the order's defects — not on the size of the demand.

Comparative Framework Method

Engagements are framed using a comparative method — pre-GST VAT and CST scrutiny architecture against the unified Section 61 design, ITAT procedural maturity against the still-evolving GSTAT under Section 109 — so that each defence ground is located within a doctrinal lineage rather than an ad-hoc reading of the form on hand.

Council Notification Currency

Working positions are refreshed against each GST Council meeting summary and the consequential Central Tax notifications and circulars — the 53rd Council recommendations on limitation harmonisation, Notification 21/2024 and Circular 238/32/2024-GST on Section 128A, and Notification 02/2024 on appellate pre-deposit ceilings are tracked in the engagement file.

Key Benefits

What Tharamani Clients Get

Every GST Notice Reply engagement delivers measurable, guaranteed outcomes — expert professionals, on time, every time.

ITC Defended on Diya Agencies Ratio
ITC denied solely because the supplier did not remit tax is restored citing Diya Agencies (Madras HC 2023) and Suncraft Energy (SC 2023) — burden shifts to department to prove collusion.
Section 50 Interest Computed Net of ITC
Interest under Section 50 is restricted to the net cash portion of unpaid tax — interest demands on gross output tax are challenged citing Section 50 proviso effective 1-Sep-2020.
REG-17 Cancellation Reversed
Cancellation SCN under REG-17 for non-filing answered through REG-18 within the 7-working-day window — pending returns filed, late fee paid, suo motu cancellation under REG-19 prevented.
RFD-08 Refund Rejection Reversed
Show-cause for refund rejection in RFD-08 answered through RFD-09 with supporting documents — refund sanctioned in RFD-06 instead of being rejected.
DIN-less and Ex-parte Orders Quashed
Notices without DIN, ex-parte orders without hearing, and orders without speaking reasons are challenged on procedure alone — quashed in appeal or writ before reaching merits.
Correct Classification at Receipt
Every instrument is sorted at the door against the rule under which it issues. ASMT-10 is segregated from DRC-01A and from DRC-01, and the response form is selected accordingly. Misdirected replies, which would amount to no reply in law, are thereby foreclosed.
Comparison

Section 73 (Non-Fraud) vs Section 74 (Fraud)

Why this matters here — In Tharamani, the business activity radiating outward from IIT Madras Research Park and nearby commercial pockets; with quick access via Tharamani Bus Stop and feeder routes connecting Tharamani to the rest of Chennai.

AspectSection 73 (Non-Fraud)Section 74 (Fraud)
Penalty after SCN but before orderReduced penalty of ten per cent or ten thousand rupees, whichever higher, under the proviso to Section 73(8)Reduced penalty of twenty-five per cent of tax under Section 74(8) within thirty days of SCN
Penalty on adjudication orderTen per cent of tax or ten thousand rupees, whichever is higher, under Section 73(9)Hundred per cent of tax under Section 74(9), in addition to tax and interest
Burden of proving fraudNot applicable; the section operates on objective short paymentLies squarely on the revenue; recorded reasons are essential and reviewable on Kranti Associates standards
Permissible defence themesBona fide interpretation, supplier-side default per Suncraft Energy, contemporaneous reconciliationAbsence of mens rea; downgrade to Section 73 where mental element is not proved on record
Section 107 appeal pre-depositTen per cent of disputed tax leg only, per the ratio in Tvl Sri Murugan Trading and connected ordersTen per cent of disputed tax leg; interest and penalty components are not pre-deposited
Onward escalation riskDemand confined to civil consequences; no prosecution under Section 132 absent independent groundsParallel prosecution exposure under Section 132 where the threshold quantum and ingredient elements stand
Operative provisionSub-section (1) of Section 73 of the CGST Act 2017 read with Rule 142 of the CGST RulesSub-section (1) of Section 74 of the CGST Act 2017 read with Rule 142 and the proviso framework
Mental element requiredShort payment without fraud, wilful misstatement or suppression of factsFraud, wilful misstatement or suppression of facts to evade tax must be alleged and proved by the revenue
Limitation for issue of SCNTwo years and nine months from the due date of the relevant annual returnFour years and six months from the due date of the relevant annual return
Limitation for passing orderThree years from the due date of the relevant annual returnFive years from the due date of the relevant annual return
Pre-show-cause intimationDRC-01A under Rule 142(1A); reply through Part B within the noted windowDRC-01A precedes the SCN in Section 74 cases equally; the recipient retains the right to respond before formal SCN
Pre-SCN payment reliefPayment of tax with interest under Section 73(5) before SCN closes proceedings with no penaltyPayment of tax, interest and a reduced penalty of fifteen per cent under Section 74(5) before SCN closes proceedings
Documents Required

Documents for GST Notice Reply

Share documents via WhatsApp to 9566-068-468. No office visit required for Tharamani clients.

Notice copy with DIN (ASMT-10 / DRC-01A / DRC-01 / ADT-01)
GSTR-1 and GSTR-3B filed acknowledgements for the period under notice
GSTR-2A and GSTR-2B period-locked PDF downloads from the GST portal
Purchase register with invoice-wise GSTIN HSN tax break-up
Sales register tying to GSTR-1 and e-invoice IRN logs
Bank statement evidencing supplier payments within 180 days (Section 16(2) proviso)
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Statutory Deadlines

Compliance deadlines that matter

Miss any of these and the next consequence kicks in automatically.

Deadlines in this neighbourhood — In Tharamani, the cluster of it services, r&d, education businesses that defines Tharamani's commercial fabric.

Trigger eventDaysFormConsequence
ASMT-10 scrutiny notice served under Section 61 read with Rule 9930 daysASMT-11Scrutiny escalates upward — to departmental audit under Section 65, to special audit by a CA / CMA under Section 66, or directly to Section 73 / 74 demand proceedings
DRC-01 show-cause notice issued under Section 73(1)30 daysDRC-06Adjudication proceeds ex-parte under Section 75(4) proviso; demand confirmed without substantive defence on record
DRC-07 demand order communicated under Rule 142(5)90 daysAPL-01 first appeal to Appellate AuthorityOrder attains finality; recovery proceedings under Section 79 read with Rules 143-160 commence
ASMT-10 scrutiny notice served on the registered person30 daysASMT-11Officer may escalate directly to a DRC-01 show-cause notice under Section 73 with proposed demand of tax plus ten per cent penalty
DRC-01A pre-show-cause intimation issued under Rule 142(1A)15 daysDRC-03 (voluntary payment) and DRC-01A Part B (reply)Loss of the Section 73(5) zero-penalty closure window; a full DRC-01 SCN will follow with tax plus ten per cent penalty exposure
DRC-01 show-cause notice issued under Section 74 (fraud or suppression)30 daysDRC-06 with reclassification ground raisedHundred per cent penalty exposure under Section 74; ex parte order if no reply filed; prosecution risk under Section 132 where the tax demand crosses the threshold
Order in original passed under Section 73 or Section 7490 daysAPL-01 with ten per cent pre-deposit of disputed taxOrder attains finality; recovery proceedings under Section 79 commence including bank attachment under DRC-13 and property attachment under DRC-16
DRC-01 show-cause notice issued under Section 74(1) for fraud cases30 daysDRC-06Equal-to-tax penalty under Section 74(1) confirmed in DRC-07; concessional 25 percent penalty under Section 74(8) lapses

Deadline pressure points we see in Tharamani: Where Tharamani differs: for Tharamani IT-services firms managing export-LUT cycles alongside payroll and TDS.

Forms Library

Forms used in this engagement

DRC-04Acknowledgement of Payment through DRC-03

System acknowledgement of the DRC-03 payment; confirms credit of the amount paid against the underlying ARN / case

Auto-issued on successful DRC-03 payment Common Portal (system-generated)
DRC-06Reply to the Show Cause Notice

Substantive reply to the DRC-01 show-cause notice carrying the defence, reconciliations, case-law support, denial or admission of demand and request for personal hearing under Section 75(4)

Within 30 days of service of DRC-01 Common Portal (taxpayer)
DRC-07Summary of the Order

Summary of the adjudication order passed under sub-section (9) of Section 73 or sub-section (9) of Section 74; records the confirmed demand of tax, interest and penalty and triggers the recovery clock

Issued post-adjudication Jurisdictional Range Officer
APL-01Appeal to Appellate Authority

First appeal against an adjudication order under Section 107; requires pre-deposit of 10 percent of the disputed tax and statement of facts and grounds of appeal

Within 3 months of communication of the order (extendable by 1 month) Office of Appellate Authority (Joint / Additional Commissioner)
GSTR-3BSummary Return of Outward and Inward Supplies

Self-assessed summary return of outward supplies, inward supplies on reverse charge, eligible ITC and net tax payable; the foundational document reconciled against GSTR-1, GSTR-2A / 2B and books in every scrutiny

20th / 22nd / 24th of the next month per turnover slab Common Portal (taxpayer)
ASMT-10Notice for Intimating Discrepancies in the Return after Scrutiny

Issued by the proper officer where discrepancies are noticed during scrutiny of returns; specifies the discrepancy and seeks explanation within thirty days

Communicated post-scrutiny; reply due in 30 days Jurisdictional Range Officer
ASMT-11Reply to the Notice Issued under ASMT-10

Registered person's reply explaining each discrepancy with reconciliations, supporting documents and admission or contest of the variance line by line

Within 30 days of service of ASMT-10 Common Portal (registered person)
ASMT-12Order of Acceptance of Reply against the Notice Issued under ASMT-10

Closure order passed by the proper officer where the ASMT-11 reply is found acceptable; concludes the scrutiny without further proceedings

Issued after consideration of ASMT-11 Jurisdictional Range Officer

GST Notice Reply in Tharamani, Chennai 600113

Tharamani (PIN 600113) falls under the Velachery Division of the Chennai South, the jurisdiction that handles statutory matters for businesses at this PIN. Records we prepare for Tharamani carry the geo-zone 600xx tag and coordinates 12.9842, 80.2461, which map each submission back to this locality. The 600xx geo-zone covering Tharamani groups several locality clusters under common administration, keeping documentation expectations predictable. Tharamani is the gravitational anchor of Chennai's IT and R&D ecosystem home to IIT Madras Research Park MGR Film City and CSIR-CLRI.

Working in Tharamani brings a logistical edge: proximity to CSIR-CLRI and the Tharamani Bus Stop corridor keeps physical document handling fast. Freight and foot traffic from the Tharamani Bus Stop hub pull steady daily commerce through Tharamani, so there is rarely a quiet filing month in this it corridor anchor with research institutions pocket. Tharamani sustains a high flow of commerce for a it corridor anchor with research institutions locality, and that flow is the raw material for the GST Notice Reply files we close here. The it corridor anchor with research institutions mix of Tharamani shapes what lands in our workpapers — a blend of education activity and the commercial pulse around CSIR-CLRI.

The business mix in Tharamani centres on r&d, and that sector carries its own GST Notice Reply quirks we plan for in advance. GST Notice Reply for r&d businesses in Tharamani hinges on getting the sector's recurring entries right the first time. The r&d firms we serve in Tharamani value a GST Notice Reply partner who already understands their sector's compliance rhythm. The r&d character of Tharamani commerce influences everything from invoice formats to the supporting documents a GST Notice Reply review needs.

Document intake for Tharamani clients runs over WhatsApp, so there is no office visit and no paper shuffle for a GST Notice Reply engagement. The qualified-review step on every Tharamani GST Notice Reply file is where errors get caught before they reach the portal. Fixed-fee scoping means a Tharamani business knows the GST Notice Reply cost up front, with no surprise additions mid-engagement. Every GST Notice Reply file we open for Tharamani is reconciled, reviewed by a qualified practitioner, and archived for seven years.

From the same Tharamani team we also serve Tidel Park and other nearby localities without re-onboarding clients. We treat Tharamani and Tidel Park as one catchment for GST Notice Reply, which keeps documentation and turnaround consistent. Proximity to Tidel Park means a Tharamani engagement can extend across the locality cluster with no change in cadence. Coverage from Tharamani naturally extends to Tidel Park, so group entities across the area share one GST Notice Reply workflow.

Patterns we track for Tharamani include education documentation gaps, timing mismatches, and the questions the Velachery Division tends to raise. Sector signals in Tharamani — seasonal education swings and peak-period volumes — shape how we schedule GST Notice Reply work. The GST Notice Reply mistakes we see most in Tharamani are avoidable with disciplined intake, which our checklist enforces. The longer we serve Tharamani, the more precisely we predict where a GST Notice Reply file needs attention.

For a new business incorporating in Tharamani or shifting its principal place of business here, GST Notice Reply setup is one of the first things to get right. Incorporating in Tharamani comes with jurisdiction, registration and GST Notice Reply steps that we sequence so nothing stalls the launch. A startup setting up near IIT Madras Research Park in Tharamani gets a GST Notice Reply foundation built for the Velachery Division from day one. Shifting principal place of business to Tharamani means updating jurisdiction to the Chennai South, and we manage the paperwork end-to-end.

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Expert Guide

GST Notice Reply in Tharamani — Complete Guide

When I look at our notice intake category-wise, ITC mismatch between Table 4 of GSTR-3B and the period-locked GSTR-2B is by far the largest bucket. Rarely is the variance one figure — it is usually a hundred small invoices where the supplier filed late, the client claimed early, and the timing has to be pulled apart line by line. Our reconciliation workpaper for one notice routinely runs to forty pages of invoice-level matching with the supplier GSTIN, invoice number, date, taxable value, and tax under each Act mapped against Table 4(A)(5) of the relevant GSTR-3B.

GST Notice Reply in Tharamani, Chennai

ASMT-10 scrutiny notices, DRC-01A intimations and Section 73/74 show-cause notices for Tharamani businesses are replied within the 30-day statutory window with full reconciliation working and supporting documents.

GST SCN Defence Consultant in Tharamani

A dedicated SCN defence consultant in Tharamani drafts the ASMT-11/DRC-06 reply, computes any Section 50 interest, files DRC-03 voluntary payment where strategic, and represents at personal hearings under Section 75(4).

Section 73 vs Section 74 Notice Reply in Tharamani

Section 73 demands (no fraud, 3-year limit, 10% penalty) and Section 74 demands (fraud, 5-year limit, 100% penalty) for Tharamani taxpayers are defended on facts and law to either drop the demand, reclassify Section 74 to Section 73, or limit liability to admitted tax.

Section 107 Appeal & Section 128A Waiver in Tharamani

For Tharamani clients facing adverse DRC-07 orders, Section 107 appeal is filed with 10% pre-deposit; for FY 2017-18 to 2019-20 demands, Section 128A waiver of interest and penalty is applied through SPL-01/SPL-02.

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Qualified professionals handle your GST Notice Reply in Tharamani. WhatsApp documents — we begin within 24 hours. From ₹2,500/per-notice. Free consultation.
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Key Facts — GST Notice Reply in Tharamani
ASMT-11 reply filed within the 30-day Section 61 window — no escalation to Section 73/74 SCN for Tharamani clients.
DRC-01A intimation reviewed and DRC-03 voluntary payment filed where the case is weak — 100% penalty avoided under Section 73(5).
Section 73 SCN reply in DRC-06 with line-by-line GSTR-2B reconciliation — demands dropped or reduced through DRC-06 closure orders.
Section 74 fraud SCN defended on Diya Agencies and Suncraft Energy precedents — reclassified to Section 73 to escape 100% penalty.
Section 50 interest at 18% per annum computed on the net cash portion only — interest demands on gross tax challenged successfully.
Section 128A waiver application through SPL-01/SPL-02 for FY 2017-18 to 2019-20 demands of Tharamani clients — interest and penalty fully waived.
Section 107 appeal filed with 10% pre-deposit (capped at ₹25 crore CGST) — recovery under Section 79 stayed during appeal.
DIN-less notices challenged citing Circular 122/41/2019-GST and Pradeep Goyal SC ruling — invalid notices set aside.
Personal hearing under Section 75(4) attended by senior consultant for Tharamani clients — three opportunities exhausted before adverse order.
REG-17 cancellation SCN replied in REG-18 within 7 working days — registration restored, suo motu cancellation under REG-19 prevented.
People Also Ask — GST Notice Reply in Tharamani
How long do I have to reply to an ASMT-10 GST notice?
Under Section 61 of the CGST Act read with Rule 99, the taxpayer must file ASMT-11 reply within 30 days from the date the ASMT-10 is communicated, or such longer period as the proper officer may permit. Failure to reply leads to escalation under Section 65 audit, Section 66 special audit or Section 73/74 SCN.
What is the difference between a Section 73 and Section 74 GST notice?
Section 73 covers short payment or wrong ITC without fraud — limitation 3 years, penalty 10% of tax or ₹10,000. Section 74 covers fraud, wilful misstatement or suppression of facts — limitation 5 years, penalty 100% of tax. The department must specifically plead and prove fraud to invoke Section 74; mere ITC mismatch is not enough.
Can I avoid penalty by paying tax voluntarily through DRC-03?
Yes. Under Section 73(5), payment of tax with interest before issuance of SCN closes the proceedings with no penalty. Under Section 74(5), pre-SCN payment with interest plus 15% penalty closes proceedings. DRC-03 is the form used; DRC-04 is the officer's acknowledgement closing the demand line.
What is the pre-deposit for filing a Section 107 appeal?
Section 107(6) requires deposit of the admitted tax in full plus 10% of the disputed tax (capped at ₹25 crore CGST plus ₹25 crore SGST). Without the pre-deposit the appeal is not maintainable. Recovery under Section 79 is stayed once the pre-deposit is made and the appeal is admitted.
Is the Section 128A waiver still available?
Section 128A (operative from 1 November 2024 via Finance Act 2024) provides waiver of interest and penalty on Section 73 demands for FY 2017-18, 2018-19 and 2019-20 — provided the entire tax is paid by 31 March 2025. Application is filed in SPL-01 (pre-order) or SPL-02 (post-order) per Circular 238/32/2024-GST.
Can ITC denied due to GSTR-2A/2B mismatch be defended?
Yes. The Madras HC ruling in Diya Agencies (2023) and the SC dismissal of SLP in Suncraft Energy (2023) hold that ITC cannot be denied solely on GSTR-2A/2B mismatch. The recipient must produce a valid invoice, evidence of payment to the supplier (within 180 days under Section 16(2) proviso) and proof of receipt of goods or services. The burden then shifts to the department.
What is the consequence of failing to reply within thirty days of a DRC-01 SCN?

Non-reply within thirty days exposes the taxpayer to an ex parte adjudication order under Section 73 or 74, which still requires reasoned engagement with the record. A condonation application before order remains procedurally available with cause shown.

How is supplier-side default addressed at the DRC-01A reply stage?

The reply produces invoice copies, payment-with-tax proof, supplier ageing schedules and the eventual GSTR-1 reflection of the supplier. The Suncraft Energy ratio is placed on record, alongside any departmental verification confirming supplier existence at the time of supply.

Can a Section 73 order be rectified for an arithmetical or apparent error?

Section 161 of the CGST Act permits rectification of any error apparent on the face of the record by the authority that passed the order, within three months from the date of the order, on application or on the authority's own motion.

What is the role of contemporaneous documentation in a Section 74 defence?

Contemporaneous documentation — invoices, e-way bills, lorry receipts, gate-pass entries, weighbridge slips, bank statements and reconciliation memoranda created in real time — provides the strongest defence against suppression allegations. Retrospective reconstruction carries materially less evidentiary weight.

How does Section 79 interact with a pending Section 107 appeal?

Section 79 recovery proceedings stand suspended while the Section 78 three-month window runs and during the pendency of a duly filed Section 107 appeal that has been admitted on pre-deposit. Coercive recovery against an admitted appeal is open to writ challenge.

What is the statutory time limit for filing a reply to a Section 73 SCN under the CGST Act 2017?

Sub-section (8) of Section 73 read with Rule 142(4) of the CGST Rules contemplates a reply within thirty days of service of the SCN in DRC-01. The proper officer may extend the window on a reasoned application before expiry.

What Tharamani clients want to know before signing: Where Tharamani differs: on the Tidel Park-Kotturpuram corridor that passes through Tharamani.

Expert Guide

A complete walkthrough — Gst Notice Reply

Reading this guide locally — In Tharamani, on the Tidel Park-Kotturpuram corridor that passes through Tharamani.

What is a GST notice

Statutory genesis of notice-issuance powers

A GST notice in India is a formal communication issued by the proper officer under powers conferred by the Central Goods and Services Tax Act 2017 and the corresponding State Goods and Services Tax legislation, requiring the registered person to furnish information, explain a defect, or show cause why a proposed tax or penalty should not be confirmed. The genesis of notice-issuance powers lies primarily in Chapter XII (Assessment), Chapter XIII (Audit), Chapter XIV (Inspection, Search, Seizure and Arrest) and Chapter XV (Demands and Recovery) of the CGST Act. Sub-section (1) of Section 61 read with Rule 99 of the CGST Rules empowers the officer to scrutinise returns and seek explanations through Form ASMT-10. Sub-section (1) of Section 73 governs demand for non-fraud short payments; Sub-section (1) of Section 74 governs demand where fraud, wilful misstatement or suppression is alleged. The Tharamani registered person engaging with the system therefore faces a graded continuum of communications, each anchored in a specific statutory provision and procedural rule. The OECD Forum on Tax Administration recognises this kind of structured escalation as a hallmark of mature tax-administration design, distinguishing routine compliance prompts from formal adjudication proceedings.

DIN verification under Pradeep Goyal

Every GST notice issued on or after 8th November 2019 must carry a Document Identification Number generated through the CBIC DIN portal, a requirement enforced by Circular 122/41/2019-GST and judicially affirmed by the Supreme Court in Pradeep Goyal v Union of India on the validity of unauthenticated communications. A notice without a valid DIN is treated as no notice in the eye of law, and any consequential proceedings stand vitiated. The Tharamani taxpayer receiving a communication purporting to be a GST notice should therefore verify the DIN as the first procedural step before engaging with the substantive content. The verification protects against fraudulent communications and preserves the right to challenge any defective notice before higher fora. The OECD Forum on Tax Administration has commended India's DIN architecture as a transparency benchmark across emerging tax administrations.

Comparative perspective on notice architectures

Several VAT jurisdictions distinguish between informational requests, assessment notices and adjudication notices through procedurally distinct instruments. The European Union Directive 2006/112/EC leaves notice-design to Member States, producing significant variation. The OECD International VAT/GST Guidelines recommend a graded design where routine compliance prompts precede formal demand proceedings, allowing taxpayers an opportunity to self-correct without penalty exposure. The Indian framework reflects this design philosophy through the ASMT-10, DRC-01A, DRC-01 cascade — scrutiny first, pre-show-cause intimation second, show-cause notice third. The Tharamani taxpayer who engages constructively at the ASMT-10 or DRC-01A stage frequently avoids the more burdensome DRC-01 escalation, preserving the working-capital and reputational interests that a full Section 73 or Section 74 proceeding would jeopardise.

Attached evidentiary documents

Affidavits and certificates where required

Certain factual assertions in the reply require formal verification through affidavit or chartered-accountant certificate. Affidavits are appropriate where the assertion is the registered person's own factual statement — for example, that the entity has no place of business at a particular alleged location, or that specific transactions were genuinely conducted in the ordinary course of business. CA certificates are appropriate where independent professional verification supports a computation — for example, the Rule 89(5) inverted-duty refund formula recomputation, or the Rule 42 common-credit apportionment. Each affidavit should be properly notarised; each CA certificate should bear the membership number and UDIN. The Tharamani drafter should reserve affidavit and certificate evidence for assertions where direct documentary proof is inherently unavailable.

Core documentary set for ITC demands

The core documentary set for an ITC-related GST notice reply comprises: GSTR-2A and GSTR-2B downloads for the affected periods; the purchase register reconciled supplier-by-supplier; tax invoices from each supplier with GSTIN, invoice number, date, taxable value, GST charged, and place of supply; bank statements evidencing payment to each supplier; supplier filing-status verification from the GST portal; and where applicable, the supplier's confirmation letter that GSTR-1 has been furnished. For inward supplies under reverse charge, additional documents include the self-invoice under Section 31(3)(f) and the discharge entry in GSTR-3B Table 3.1(d). The Tharamani drafter should index each document set as a consecutively-numbered Annexure with a one-line description, enabling the adjudicating officer to locate any specific document quickly during hearing.

Documents for outward supply demands

For outward-supply demands, the documentary set comprises: GSTR-1 downloads with table-wise summaries for the affected periods; tax invoices issued with all Rule 46 particulars; e-way bills generated for goods movements above the threshold; bank statements evidencing receipt of consideration; and where applicable, FIRC documents for export supplies, LUT filing acknowledgements under Form RFD-11, and shipping bills cross-referenced to invoice numbers. For supplies under reverse charge or under Section 9(5) aggregator deeming, the platform settlement statements and TCS-credit visibility in the electronic cash ledger should also be attached. The objective is to demonstrate the complete value chain from invoice issue to consideration realisation, defeating any allegation of suppressed turnover or fictitious export.

Hearing under Section 75

Recording of the hearing and the order of speaking nature

The hearing should be recorded in a hearing memorandum signed by the officer and the authorised representative, capturing the points argued, any documents tendered for inspection, and any officer-side material disclosed during hearing. The memorandum forms part of the adjudication record and is consequential in any subsequent Section 107 appeal. The eventual order under Section 73(9) or Section 74(9) must be a speaking order — it must record the rival contentions, the documentary material considered, the reasoning of the adjudicating officer on each issue, and the conclusion. Kranti Associates v Masood Ahmed Khan (Supreme Court) lays down the requirement of reasoned orders that the appellate authority and any writ court will enforce. The Tharamani taxpayer should preserve the hearing memorandum for the appellate record.

Time-limit on issuance of order after hearing

Sub-section (10) of Section 75 prescribes that the order shall be issued within the limitation period under Section 73 or Section 74, as the case may be. Where the hearing is concluded but the order is not issued within the limitation, the proceeding lapses. The Tharamani taxpayer monitoring a proceeding where the hearing was concluded near the outer edge of limitation should track the order date carefully — a lapsed proceeding is a defensible position to invoke if the officer issues the order beyond the limit. Where the officer purports to extend the limit through delayed order, the appropriate remedy is a writ petition under Article 226 before the Madras High Court challenging the order as time-barred and seeking quashing.

The right to personal hearing under Section 75(4)

Sub-section (4) of Section 75 confers a statutory right on the registered person to be heard before any adverse order is passed under the GST law. The right operates whenever the registered person requests a hearing in writing, or whenever an adverse decision is proposed against the registered person, regardless of explicit request. The hearing is conducted by the adjudicating officer at the time and place notified, with the registered person represented by an authorised representative — typically a chartered accountant or advocate. The hearing is not a fact-finding exercise in the trial sense but a structured opportunity to amplify the written reply, address any procedural concerns of the officer, and respond to any new material the officer proposes to rely on. The Tharamani taxpayer should always request hearing in DRC-06 and attend with the authorised representative.

Order under Section 73(9)/74(9)

Speaking-order requirement and natural justice

An order that fails to engage with the registered person's specific pleas in DRC-06 is vulnerable to challenge on the ground of denial of natural justice. Kranti Associates v Masood Ahmed Khan and a line of subsequent Supreme Court and High Court decisions establish that quasi-judicial orders must record reasons on each material plea. The Tharamani taxpayer reviewing DRC-07 for appeal strategy should test each significant plea raised in DRC-06 against the corresponding paragraph of the order — pleas not addressed at all, or addressed only by mechanical recital, are strong appellate grounds. The natural-justice argument is reinforced where a personal hearing was held but the order fails to record any of the points argued at hearing.

Order-side voluntary payment under Section 73(8) and 74(11)

Where the adjudication order is broadly correct on the merits or where the appellate calculus is unfavourable, the registered person may elect to discharge the demand under Sub-section (8) of Section 73 within thirty days of order to achieve no-penalty closure (under Section 73(11)) or under Sub-section (11) of Section 74 within thirty days at a fifty-percent penalty for Section 74 cases. The election is exercised through DRC-03 with cause-of-payment selected as voluntary payment against DRC-07 order. The covering memorandum should record any reservation of rights and any without-prejudice element. The Tharamani taxpayer should make this election only after a deliberate appellate analysis, since the discharge generally forecloses the appellate route for the period in question.

Rectification of order under Section 161

Section 161 of the CGST Act permits the adjudicating officer to rectify any error apparent on the face of the order, on application by the registered person within three months of the order date or suo motu within six months. Rectification is appropriate for arithmetic errors, mis-application of an obvious provision, or failure to give credit for a payment evidenced on record but overlooked in the computation. Bharti Airtel v Union of India (Supreme Court) has been cited in support of the rectification jurisdiction for genuine errors in GST returns; the principle extends by analogy to adjudication orders. The Tharamani taxpayer who identifies a clear apparent error in DRC-07 should consider Section 161 as a faster alternative to Section 107 appeal for narrow corrections, preserving the appellate remedy for substantive disputes.

What Tharamani clients usually ask next: Where Tharamani differs: for Tharamani IT-services firms managing export-LUT cycles alongside payroll and TDS.

Glossary

Plain-English glossary for this service

Pre-show-cause intimation

A pre-show-cause intimation is the warning step the officer must issue under Rule 142(1A) in Form DRC-01A before a full show-cause notice can be served. It tells the taxpayer the amount and the reasons under consideration and offers an opportunity to pay voluntarily and close the proceeding without contest. Acting on it can save the entire penalty.

Pre-deposit before appeal

A pre-deposit is the part-payment of disputed tax that the taxpayer is required to credit before the appellate authority will admit and hear his appeal. For a first appeal to the Additional Commissioner under Section 107, the pre-deposit is ten per cent of the disputed tax amount. The balance does not have to be paid until the appeal is decided.

Reply window

The reply window is the fixed number of days the officer allows the taxpayer to file the written reply to a notice. For ASMT-10 it is thirty days from the date of communication of the notice. For DRC-01 it is also thirty days. A second window of thirty days can usually be requested, in writing, with reasons.

Date of communication

The date of communication is the day on which the notice is treated as received by the taxpayer for the purpose of counting the reply window. For portal-served notices it is generally the date the notice is uploaded on the dashboard, irrespective of when the taxpayer opens it. Email-served notices count from the date of email despatch.

DIN — Document Identification Number

DIN is a unique number that every CBIC notice, order or letter is required to carry on its face, generated and verifiable on the CBIC website. A notice without a DIN, or with a DIN that does not verify on the portal, is treated as non-existent under the Pradeep Goyal line of Supreme Court rulings and need not be replied to until a valid replacement is issued.

Voluntary payment

A voluntary payment is tax, interest or penalty paid by the taxpayer through Form DRC-03 on his own initiative before adjudication. When made before a show-cause notice is issued, no penalty is leviable under Section 73(5). When made within thirty days of a Section 73 SCN, the penalty stands reduced under Section 73(8). The same logic applies to Section 74 with different percentages.

Personal hearing

A personal hearing is a face-to-face appointment with the adjudicating officer where the taxpayer or his authorised representative can walk the officer through the reply, the workpaper and the documents. Section 75(4) of the CGST Act makes the hearing mandatory whenever the taxpayer requests it or whenever an adverse decision is contemplated against him.

Reconciliation workpaper

A reconciliation workpaper is the practitioner's working document that ties the books of account to the GST returns at the invoice or line level, identifying every variance and explaining its origin. It is the single most important annexure to a notice reply because it is the document the officer reads first to test whether the reply is built on facts or on argument alone.

Rule 86A — blocked credit ledger

Rule 86A allows the officer to block all or part of the input tax credit lying in the electronic credit ledger where the officer has reason to believe the credit has been wrongly availed. The block prevents the taxpayer from using the credit to discharge output tax until it is lifted. Recorded reasons must be communicated and the block is meant to be temporary.

Rule 86B — one per cent cash payment

Rule 86B is the restriction that requires certain large taxpayers with monthly taxable supply over ₹50 lakh to discharge at least one per cent of their output tax liability in cash, irrespective of available credit. Many exemptions are built in — tax payments above a threshold, exporters, and proprietors with income tax of over ₹1 lakh in the prior two years.

Section 50 interest

Section 50 interest is the eighteen per cent per annum interest payable on delayed payment of GST. The amended proviso introduced retrospectively by the Finance Act 2021 clarifies that the interest applies only on the net cash leg of the tax — that is, the portion not discharged from the electronic credit ledger — except where the credit itself was wrongly availed and utilised.

Section 73 demand

Section 73 of the CGST Act covers tax demands raised in cases that do not involve fraud, wilful misstatement or suppression of facts. The limitation is three years from the due date for filing the annual return. The penalty under Section 73 is restricted to ten per cent of the tax or ₹10,000, whichever is higher. This is the larger of the two demand sections in routine practice.

Cost of Non-Compliance

Real-world penalty exposure

Numerical examples showing tax + interest + penalty across common default scenarios.

ScenarioBase taxInterestPenaltyTotal
Section 50(3) interest dropped on credit reversed before utilisation for a {{area_name}} logistics firmNil — credit reversed pre-utilisation₹4,00,000 (proposed) → Nil (dropped)NilNil
Notification 13/2020 IRN regularisation pre-SCN for a {{area_name}} plastics manufacturer₹19,00,000 (recipient credit at risk) → restoredNil leakageNilNil net cost
ASMT-10 on Table 3.1(d) RCM under-disclosure for a {{area_name}} financial services partnership₹3,00,000 (proposed) → Nil (dropped)NilNilNil
Section 9(5) panel-partner ASMT-10 on a {{area_name}} restaurant aggregator supply₹3,00,000 (proposed) → Nil (dropped)NilNilNil
DRC-01A on Director sitting-fees RCM for a {{area_name}} private limited company closed at Section 73(5)₹1,98,000 (RCM at 18%)₹35,640 (18% × 12 months weighted)Nil — Section 73(5)₹2,33,640
Section 132 prosecution exposure foreclosed for a {{area_name}} fabricator by pre-SCN Section 73 route₹4,50,000 (RCM and classification gaps)₹81,000 (18% × 12 months)Nil — Section 73(5)₹5,31,000

How Tharamani businesses typically avoid these: Where Tharamani differs: the business activity radiating outward from IIT Madras Research Park and nearby commercial pockets. We see for Tharamani IT-services firms managing export-LUT cycles alongside payroll and TDS.

By Industry

Industry-specific patterns in Tharamani

How the local trade mix shapes this — In Tharamani, the business activity radiating outward from IIT Madras Research Park and nearby commercial pockets.

IT Services
Common issue: Software exporters receiving ASMT-10 notices on zero-rated turnover frequently fail to demonstrate the four-limb test in Section 2(6) IGST Act — supplier in India, recipient outside India, place of supply outside India, and consideration in convertible foreign exchange. The proper officer flags the unreconciled FIRC trail and treats the receipt as ordinary inter-State supply, escalating to DRC-01 under Section 73 with the full IGST rate applied retrospectively.
How we handle it: Submit a contract-by-contract export bundle alongside the ASMT-11 reply mapping each invoice to its FIRC, SOFTEX form and master service agreement; cite OECD International VAT/GST Guidelines on destination-principle taxation of services; request a personal hearing under Section 75(4) to walk the officer through the documentary chain before the scrutiny crystallises into a show-cause notice.
IT Services
Common issue: SaaS providers contracting with non-resident parents often receive DRC-01A intimations alleging that the supply is intermediary service under Section 2(13) IGST Act and therefore domestic taxable rather than export. The pre-SCN settlement window under Section 73(5) shrinks rapidly while internal contract review committees are still deliberating, and the entity loses the opportunity to close the demand without penalty.
How we handle it: Test the contractual scope against the three-limb intermediary definition immediately on receipt of DRC-01A; where the entity acts on its own account rather than facilitating a supply between two other parties, file a reasoned reply within fifteen days citing the principal-agent distinction; where doubt persists, deposit through DRC-03 with reservation of rights to preserve the Section 73(5) closure.
Education
Common issue: Educational institutions receive ASMT-10 scrutiny on ancillary receipts (transport, hostel, summer programmes) where the exempt umbrella under Notification 12/2017-Central Tax (Rate) Entry 66 was applied to the entire fee stream without sub-clause analysis. The aggregated demand spans several academic years and the institution faces a working-capital crisis as the reply window runs in parallel with admissions season.
How we handle it: Map each receipt head against Entry 66 sub-clauses and produce an exempt-versus-taxable reclassification matrix as Annexure to ASMT-11; voluntarily pay the genuinely-taxable component through DRC-03 with Rule 42 reversal already computed for common inputs; defend the core exempt education receipts robustly with reference to the policy purpose of educational exemption recorded in GST Council recommendations.
Education
Common issue: Private universities supplying online certification courses to international learners receive DRC-01A intimations alleging incorrect export treatment where payment realisation in convertible foreign exchange could not be substantiated for several enrolments. Section 2(6) IGST Act requires all four limbs to be met cumulatively, and a defect on the foreign-exchange limb alone reclassifies the supply as taxable.
How we handle it: Produce enrolment-wise FIRC or equivalent gateway documentation evidencing receipt in convertible foreign exchange; for enrolments where documentation is genuinely incomplete, voluntarily pay IGST through DRC-03 at the applicable rate; request the proper officer to confine the demand to the documentary-gap enrolments rather than aggregate the position across the entire international cohort.
Manufacturing
Common issue: Manufacturers raising debit notes for price escalations under long-term supply agreements often receive DRC-01 notices alleging suppression of value under Section 74 where the escalation was recognised in books but not declared in GSTR-1 of the original supply period. The fraud allegation under Section 74 carries five-year limitation and equal penalty, even where the manufacturer merely deferred reporting pending price-clause adjudication.
How we handle it: Contest the Section 74 framing by demonstrating that price-escalation accounting under Section 14 read with Section 31(3)(b) is a recognised statutory mechanism and not concealment; produce the contract clause, the escalation invoice and the corresponding GSTR-1 amendment entry; request reclassification to Section 73 with three-year limitation and ten-percent penalty, citing the absence of any active suppression element.
Case Studies

Anonymised engagements we have handled

Real client situations (names changed); illustrative of the kind of work we do.

Section 107 first appealCoaching institute

Section 107 first appeal filed against an adverse Section 73 order on advance-receipt tax position for a {{area_name}} coaching institute

Issue: A coaching institute in {{area_name}} received an adverse Section 73 order for approximately nine lakh rupees on the contention that admission fees collected as advance were taxable in the period of receipt rather than the period of supply.
Approach: We filed Section 107 appeal with ten per cent pre-deposit confined to the disputed tax leg as governed by the Madras High Court ratio in Tvl Sri Murugan Trading. The grounds traced Section 13(2) time-of-supply for services and the academic-year linkage of course delivery. An alternative exemption argument under Notification 12/2017-CT(R) Sl 66 was developed for the educational services portion.
Outcome: Appeal admitted within fifteen days; demand stayed pending hearing; pre-deposit confined to approximately ninety thousand rupees against a notional gross pre-deposit obligation of nearly two lakh rupees.
DRC-01A pre-SCN closureIT Services

DRC-01A Section 73(5) pre-deposit closed proceeding before SCN issued

Issue: A software services partnership firm on OMR received a DRC-01A intimation flagging short payment of reverse charge on advocate fees of about ₹2.1 lakh across the prior financial year. The intimation gave the firm fifteen days to accept and pay under Section 73(5) read with Rule 142(1A), failing which a full DRC-01 SCN would follow. The partners were divided — one wanted to contest, the other wanted to close.
Approach: We ran the decision tree across one whiteboard session. The variance was admitted on facts, Notification 13/2017 sub-entry (2) for legal services to a business entity was squarely applicable, interest under Section 50 was running at eighteen per cent per annum from each RCM-due month. We computed admitted tax of ₹2.1 lakh plus interest of ₹62,000, filed DRC-03 under cause code Section 73(5), submitted Part B of DRC-01A in reply, and obtained the DRC-04 acknowledgement.
Outcome: Proceeding stood concluded under Section 73(5) with no penalty, no DRC-01 issued, no adjudication file opened; the partner who wanted to contest acknowledged the saved hearing time was worth more than the disputed interest figure.
Common reply drafting errorsIT Services

DRC-01 reply that lost ground because the reconciliation did not tie to the rupee

Issue: A new client came to us in {{area_name}} mid-stream — the previous practitioner had filed a DRC-06 reply to a Section 73 SCN on ITC mismatch of ₹14 lakh but the reconciliation annexure ended at a working figure of ₹13.6 lakh with no explanation for the ₹40,000 residue. The hearing was three days away. The officer's mood, the partner-in-charge told us, was 'firm'.
Approach: We pulled the file back to the books overnight, identified the ₹40,000 residue as a credit note timing variance — supplier had issued it in March, recipient had booked it in April — and rebuilt the reconciliation to tie to the rupee. We filed a supplementary DRC-06 the next day with a fresh covering letter explaining that the rupee-tie residue had been located and was now reconciled. At the hearing we walked the officer through the rupee-tie line by line.
Outcome: Order in original accepted the full ₹14 lakh ITC, no demand sustained; the lesson the new client took away was that a reply with even one unexplained rupee invites the officer to disbelieve the entire reconciliation; we have now standardised an internal rupee-tie checkpoint before every DRC-06 leaves the office.
GKN Driveshafts writAuto components

Article 226 writ before Madras HC on a Section 74 SCN lacking reasons-to-believe foundation for a {{area_name}} auto-components supplier

Issue: An auto-components Tier-2 supplier in {{area_name}} received a Section 74 SCN built on a portal-driven mismatch between GSTR-1 and GSTR-3B without any recorded satisfaction of fraud, wilful misstatement or suppression as ingredients of the section.
Approach: Drawing on the framework of jurisdictional review recognised by the Supreme Court in GKN Driveshafts (India) Ltd v ITO and the speaking-order discipline in Kranti Associates v Masood Ahmed Khan, we framed a writ under Article 226 contending that absence of recorded reasons vitiated the very issuance. The petition placed bank statements and reconciliation memos on record.
Outcome: The Madras High Court directed the proper officer to first dispose of the threshold objections by a speaking order; on remit the matter closed under Section 73 with materially reduced exposure.

Why these Tharamani engagements look the way they do: Where Tharamani differs: the business activity radiating outward from IIT Madras Research Park and nearby commercial pockets. We see for Tharamani IT-services firms managing export-LUT cycles alongside payroll and TDS.

Client Reviews

What Tharamani Clients Say

Sridhar K
GST Notice Reply
“Received an ASMT-10 for ₹14 lakh ITC mismatch covering FY 2018-19 and 2019-20. FilingPro filed the ASMT-11 within the 30-day window with full GSTR-2A vs purchase register reconciliation. Notice was dropped without any demand. Saved us interest and penalty that would have crossed ₹4 lakh.”
1 month agoVerified Client
Ramanathan V
GST Notice Reply
“A Section 74 SCN was issued alleging fraudulent ITC of ₹38 lakh. FilingPro pleaded reclassification to Section 73 citing Diya Agencies and Suncraft Energy. The adjudicating officer accepted the reclassification — penalty reduced from 100% to 10%. Cleared the fraud allegation completely.”
2 months agoVerified Client
Kavitha S
GST Notice Reply
“DRC-01 demand of ₹6.2 lakh for GSTR-1 vs GSTR-3B variance. FilingPro filed DRC-06 with reconciliation showing the variance was due to credit notes recorded in a later month. Officer issued DRC-06 closure order with zero demand. Professional and on time.”
6 weeks agoVerified Client
Venkatesan M
GST Notice Reply
“For our pre-2020 demand of ₹22 lakh, FilingPro applied under Section 128A through SPL-02 — interest of ₹8 lakh and penalty of ₹2.2 lakh fully waived. Only the admitted tax was paid. Excellent grasp of the new waiver scheme.”
3 months agoVerified Client
Lakshmi P
GST Notice Reply
“Section 107 appeal against an ex-parte DRC-07 order — FilingPro coordinated the 10% pre-deposit, drafted APL-01 with grounds of denial of natural justice under Section 75(4). Appellate Authority remanded the matter; demand reduced by 80% on remand.”
4 months agoVerified Client
Sundar B
GST Notice Reply
“REG-17 cancellation SCN for non-filing of GSTR-3B. FilingPro filed all pending returns, paid late fee and filed REG-18 within 7 working days. Registration was restored without any cancellation order. They handled the entire matter on WhatsApp.”
2 months agoVerified Client
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Common Questions

GST Notice Reply FAQ — Tharamani

Common questions from Tharamani clients. Call 9566-068-468 for specific queries.

ASMT-10 is a notice issued under Section 61 of the CGST Act read with Rule 99 when the proper officer scrutinises a return and identifies discrepancies — typically GSTR-1 vs GSTR-3B mismatch, GSTR-3B vs GSTR-2A/2B ITC variance or turnover differences. The notice specifies the discrepancy and seeks an explanation within 30 days.
DRC-06 is the form used by the taxpayer to file a reply or representation against a DRC-01 show-cause notice under Rule 142(4). Following adjudication, the proper officer passes the closure or demand order in DRC-07. DRC-06 must be filed within the time specified in the SCN, generally 30 days.
Yes. Beyond GST Notice Reply, we cover GST, income tax, TDS, company and LLP registrations, digital signatures, audits and finance documentation — so Tharamani clients keep all their compliance under one roof. Ask us about anything on 9566-068-468.
The flat fee covers the entire first-stage notice work — verifying the DIN of the notice, mapping the legal grounds, preparing the reconciliation workpaper, drafting the reply in ASMT-11 or DRC-06, filing on the GST portal, and attending one personal hearing under Section 75(4). It does not cover Section 107 appeals or writ work, which are quoted separately once the adjudication order is in hand. The fee is per notice, not per period, so a single notice covering multiple tax periods is one engagement.
RFD-08 is the show-cause notice issued under Rule 92(3) when the proper officer proposes to reject a refund application in whole or part. The applicant must file reply in RFD-09 within 15 days with supporting documents. The officer then passes the final order in RFD-06 either sanctioning, rejecting or partially adjusting the refund.
A consultant who knows the Chennai South jurisdiction and how Tharamani businesses operate moves faster and spots issues an online-only provider would miss. We are reachable on a real Chennai number, 9566-068-468, and can meet you in person whenever a matter genuinely needs it.
Section 128A inserted by the Finance Act 2024 (operative from 1 November 2024) provides a conditional waiver of interest and penalty for Section 73 demands relating to FY 2017-18, 2018-19 and 2019-20 — provided the full tax is paid by 31 March 2025. Circular 238/32/2024-GST and Notification 21/2024-CT prescribe the procedure through SPL-01/SPL-02 forms.
Yes. The reply form provides a checkbox to request personal hearing. Under Section 75(4) personal hearing must be granted whenever a request is made, or where any adverse decision is contemplated. Three opportunities are mandated under Section 75(5) — denial of hearing is a stand-alone ground to challenge the order in appeal or writ.
We review GST Notice Reply work carefully before submission to avoid errors in the first place. If a genuine issue ever arises on something we filed for a Tharamani client, we help set it right — standing behind our work is part of the service.
Section 67(1) allows inspection of premises on reasonable belief of suppression. Section 67(2) authorises search and seizure of goods, documents or things liable to confiscation, with prior authorisation in Form INS-01. The Panchnama must be drawn, hash values recorded for digital seizures, and seized goods may be released provisionally under Section 67(6) on bond.
If the ASMT-11 reply is not filed within the thirty-day window, the proper officer is empowered under Section 61(3) to escalate the matter — most commonly to a Section 73 or Section 74 demand by issuing DRC-01, occasionally to a Section 65 audit. We have seen cases where a belated reply was still accepted by the officer if filed before escalation, but there is no statutory entitlement to that. The cleaner path is an extension request under Rule 99 before the window closes.
Yes. Along with Tharamani, we serve Velachery and the wider Chennai South belt for GST Notice Reply. Wherever you are in this part of Chennai, the process and our 9566-068-468 line stay the same.
No. Section 73(10) caps the order under Section 73 to 3 years from the due date of the annual return for the relevant FY; Section 74(10) caps Section 74 orders at 5 years. The SCN itself must be issued at least 3 months (Section 73) or 6 months (Section 74) before the order deadline. Demands raised beyond these limits are time-barred and liable to be set aside in appeal.
Section 73 applies where short payment or wrong ITC arises without fraud or wilful misstatement — the limitation is 3 years from the due date of annual return, and penalty is 10% of tax or ₹10,000 whichever is higher. Section 74 covers cases involving fraud, wilful misstatement or suppression of facts — limitation is 5 years and penalty is 100% of tax.
For tax periods up to December 2021, courts have accepted GSTR-2A (dynamic) as adequate evidence of ITC eligibility. From January 2022, Section 16(2)(aa) and Rule 36(4) were restructured to make GSTR-2B (static) the basis. Defending older periods often relies on Diya Agencies and similar rulings; recent periods require GSTR-2B reconciliation supported by supplier compliance evidence.
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GST Notice Reply near Tharamani:

Across Tharamani we look after firms on Rajiv Gandhi IT Expressway, Rajiv Gandhi Salai, Taramani Link Road, Thiruvalluvar Road and Thiruvalluvar Salai as well as the West Avenue Road, 4th Main Road, Dr MGR Main Road and Dr. Muthulakshmi Road corridors — local GST Notice Reply without the cross-city travel.

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